Document by3E3Oo3JvqVJvdXr6XKkq2Dg

VINYL CHLORIDE EMISSIONS CONTROL PROGRAM PLANT "B" SHIPPING DEPARTMENT 1990 SL 091321 VINYL CHLORIDE EMISSIONS CONTROL PROGRAM PLANT "B" SHIPPING DEPARTMENT INTRODUCTICN Vinyl cnl'jrids monomer (VCM) is a cancer suspect agent. Federal laws apply to the manufacture, handling, and storage of VCM. Specifically, these laws deal with employee eposurs to VCM and to the amount of VCM that can be re Isased to the environment. Employee exposure limits are set by the Occupational Safety and Health Act (QSHA). The current OSHA permissible exposure limit for VCM is as follows: (1) No employes may be exposed to VCM at concentrations greater than 1 ppm averaged over any 8 hour period; (2) no employee may be exposed to VCM at concentrations greater than 5 ppm averaged over any period not exceeding 15 minutes; C3> no employee may be exposed to VCM by direct contact with liquid VCM. Releases of VCM to the environment are governed by the Environmental Protection Agency (ERA). Following ERA guidelines, PPG has established a leak detection program in all areas of VCM manufacture, storage, or handling. The Plant "3" Shipping Department has such a leak detection program. The program covers the VCM tank car loading rack and is outlined in the remainder of this section of the standard operating manual. LEAH DETECTION - VCM LOADING RACK A. Fixed Point Monitoring An Areas - The Snipping Department is responsible for maintaining the instrument gas supplies. Gas cylinders must be checked daily to insure an adequate supply is on hand. The pressure of each cylinder connected to trhe analyser also must be noted and recorded on too cylinder log sheet. i -- SL 091322 The Areas, system provides for alarm and leak detection. A detection of 5 pom (parts per million) or greater is classified as an alarm. An audible alarm sounds on the tank car loading rack at an alarm panel, while indicating lights snow the sample point which is alarming. An alarm will also sound in both the EC/HCL and VCII control rooms. Personnel at these two units are responsible for investigating all leaks detected at the tank car loading rack when Shipping personnel are not working at the rack. = alarm at the tank car rack alarm panel will sound until it is acknowledged by Shipping (or other) personnel. Two successive detections of 5 ppm or gr=ater is classified as a leak. All analytical determinations are recorded on a hard copy printout in EC/HCL control room, showing the sample point and level of VC detected. Operators at EC/HCL will notify Shipping personnel as to the sample point and level O'f VC for each alarm. Shipping personnel are . responsible for correcting the leak problem. Once the leak has been eliminated, notify EC/HCL personnel to report the corrective action taken to resolve the leak. The operator will record this information on the hard copy printout, which will be maintained in tne unit's files. The sample paints, as they are identified on the printout and the alarm panel are shown below: Sairple Point Locat ion for VCM hpni tor S treaai S t ream Stream Stream Stream Stream S t r earn Stream Stream Stream i p 3 4 5 6 7 S 9 10 Tr ac k 4 Track 4 Track 4 Tr ac k 4 Track Track Track 5 s ES Track 5 Scare Calioration Station Station Station Station Station Station Station Stat ion 1 p 3 4 1 a 3 4 Pop 1 clu i '3 C o n i t o r i n g c, A i ''' G 'cel PL 101 or a TIP 11 model is employed for : as 1 " lea! da z sc t ion. The instrument is I 3, 1 :L. ' .. t i d w e s 1 1 y a nd is used for both 1eak patrol 3, n 0! a : r g z ir t i i g lea k s cat ected by the fixed point t v r' l Z 2 ~ o j s t e m . _3_ SL 091323 C The VCM lead: rack ia ajr.e/ed cnr. 3 csr week using the -r,j :c'ta:ia anj 1 /zr , inc I^tsd in this survey 15 a chech of flanges, valves, pump seals, Drassure gauges, etc. Results of this monitoring are recorded on a form arid the " eerr os retained in the Shipping [startn ant files. R ljO.au. o iiaiisa oy the Rrcas analyzer is defined as t .-iQ success 1 v e o e t a c t 10ns f 5 o g n V C M o r greater . hi hen a leaf occurs it must be located and eliminated bv tnc- sroT'ti action oloading personnel or their S p r 1szrs The procedure below outlines the steps to be taken whan Pah iious. Pricadurs for Locatinq a VCM Leak CT o etermme the location of the -leak as indicated y the alarm panel, 2. Rearing a full face breathing air mask, inspect the area near the alarming station in an effort tc determine the leak source visually. If a leak is found, attempt to correct it by appropriate action. 3. If visual inspection is unsuccessful, employ the hNU Model P 101 portable analyzer and continue to seek out the leak source. Correct any leak found by taking appropriate action. NOTE: Notify your supervisor to assist you with the HMU if necessary. R. Complete the 7CM leak report. Record the date, time, ca^se, s^d location of leak on the "Leak R e c o r t 1 a -i d in the PCM ^ack logbook. Include a orlef statement of your corrective action to el urn: [-ate t - 0 Leak. Rise, report your corrective action, to the EC/MCL operator. _n_ SL 091324